Justia Kentucky Supreme Court Opinion Summaries

Defendant was charged with manufacturing methamphetamine and possession of drug paraphernalia. Defendant filed to sequential motions to suppress evidence, contending that the warrantless search of his mobile home was illegal and that the Commonwealth did not establish the proper chain of custody for the evidence seized from his home. Both motions were denied, and Defendant was found guilty as charged. The Supreme Court reversed and remanded, holding that the warrantless search of Defendant's mobile home satisfied neither the textual directives of the Fourth Amendment and Section 10 of the Kentucky Constitution nor the judicially-created exception under Maryland v. Buie.View "Brumley v. Commonwealth" on Justia Law

After a prison disciplinary hearing, Appellant, a prisoner, was found guilty of committing physical action against another inmate resulting in death or serious physical injury. Appellant subsequently filed a declaration of rights action in circuit court appealing the finding of guilt, contending that his due process rights were violated because the prison’s disciplinary hearing officer refused to allow him to call the victim of the assault and declined to view surveillance camera footage of the incident. The circuit court denied the petition. The court of appeals affirmed. The Supreme Court reversed, holding (1) if a prison challenges the denial of a prisoner’s request for a particular witness in a disciplinary proceeding by appealing the discipline imposed, the adjustment officer (AO) must provide for the record on review the AO’s reason for denying the witness; (2) if requested by the prisoner in a disciplinary proceeding an AO must review surveillance footage or similar documentary evidence; and (3) Appellant was found guilty and subject to prison discipline as a result of a process that failed to comport with the minimum requirements of due process. Remanded. View "Ramirez v. Nietzel" on Justia Law

Appellee was an inmate when he was allegedly involved in a riot. During an interview with an investigating officer, Appellee requested that three witnesses be questioned who could corroborate his version of events, but the witnesses were not interviewed. After a disciplinary hearing, at which Appellee did not call witnesses or present evidence in his defense, Appellee was disciplined for his participation in the riot. Appellee subsequently filed a petition for declaration of rights in the circuit court, arguing that Appellants violated his due process rights by failing to interview the three purported witnesses and by denying him the right to call witnesses and present evidence in his defense. The trial court dismissed the complaint, concluding that the hearing complied with the minimal requirements of procedural due process as outlined in Wolff v. McDonnell. The court of appeals reversed. The Supreme Court affirmed, holding (1) the interviewing officer’s failure to interview the requested witnesses did not deprive Appellant of procedural due process as outlined in Wolff; but (2) while Appellee did not have had the right to remain silent or the right to an attorney during his disciplinary hearing, he deserved a new disciplinary hearing because he was erroneously informed that he enjoyed the rights espoused in Miranda. View "White v. Boards-Bey" on Justia Law

After a jury trial, Appellant was found guilty of one count of complicity to murder and one count of first-degree complicity to robbery. Appellant was sentenced to life imprisonment on the murder count and to twenty years on the robbery count. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the trial court did not err by denying Appellant’s motions for mistrial after the Commonwealth referenced two of the three co-indictees’ guilty pleas in the presence of the jury; (2) the trial court did not err by admitting eighteen jail letters written by Appellant and her co-indictee into evidence; and (3) the trial court did not err by denying Appellant’s motion for a mistrial after the jury briefly accessed inadmissible evidence during deliberations. View "Mayse v. Commonwealth" on Justia Law

After a jury trial in 1993, Appellant was found guilty of murdering two brothers, Rodney Vaughn and Lynn Vaughn. The trial court sentenced Appellant to death for both murders. In 2013, Appellant filed a motion for post-conviction relief alleging that he was entitled to a new trial based on “newly discovered evidence.” Appellant’s challenge to his convictions was founded upon a report prepared by John Nixon, a forensic expert on firearms and ballistics, who concluded that new information supported Appellant’s version of events, thereby supporting Appellant’s claim that he acted in self-defense in shooting Rodney and that Rodney shot Lynn. The trial court summarily denied Appellant’s motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding that the “newly discovered evidence” presented by Appellant fell short of the standards that must be met to obtain such relief. View "Foley v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of murdering his wife and sentenced to life in prison. On appeal, Appellant alleged, inter alia, that he was entitled to a directed verdict and that the trial court erred in admitting evidence of other acts. The Supreme Court reversed Appellant’s conviction and remanded for further proceedings, holding (1) Appellant was not entitled to a directed verdict of acquittal and therefore may be retried; and (2) the trial court’s admission of the other acts evidence was error under Ky. R. Evid. 404(b) given the Commonwealth’s failure to establish proof of the factual condition necessary to make it relevant, and the error was not harmless and prejudiced Appellant. View "Southworth v. Commonwealth" on Justia Law

Appellant was convicted of rape in the first degree, sodomy in the first degree, and assault in the fourth degree, third offense. The trial in this case was trifurcated. During the first phase, the jury convicted Appellant of fourth-degree assault, and during the second phase, the jury convicted Appellant of fourth-degree assault, third offense based on two prior convictions of fourth-degree assault. The Supreme Court reversed the portion of the judgment convicting Appellant of fourth-degree assault, third offense, and vacated the corresponding sentence for that offense, holding that the evidence was insufficient to support the charge and that retrial for the charge was precluded under the double jeopardy clause of the Fifth Amendment. Because Appellant was not sentenced for the fourth-degree assault conviction, however, the case was remanded for sentencing for that conviction. View "Galloway v. Commonwealth" on Justia Law

After a trial, Appellant was convicted of one count of first-degree rape and one count of first-degree sexual abuse for an incident involving his fourteen-year-old stepdaughter. The Supreme Court reversed, holding (1) insufficient evidence supported Appellant’s conviction for first-degree rape because the Commonwealth did not prove the “forcible compulsion” element; (2) the trial court did not err in admitting Appellant’s computer password into evidence; and (3) the trial court committed reversible error when it did not allow Appellant to ask the victim about her prior inconsistent statement, and thus, Appellant’s conviction for first-degree sexual abuse must also be reversed. Remanded. View "Yates v. Commonwealth" on Justia Law

Appellee was the target of a drug investigation conducted by investigators from the Office of the Attorney General (“OAG”) and Operation UNITE, a task force receiving federal funds that investigates drug-related crimes. No local law enforcement officer or entity participated in the investigation. Two indictments were returned by a Powell County grand jury charging Appellee with several drug-related offenses. Appellee moved to dismiss the indictments against him, holding that neither the OAG officers nor the Operation UNITE detectives had jurisdiction to conduct the investigation. The trial court denied the motion to dismiss. The court of appeals reversed, concluding that the OAG was not vested with statewide jurisdiction to investigate drug crimes. The Supreme Court reversed, holding that Ky. Rev. Stat. 218A.240(1) specifically vests the OAG with the authority to enforce and investigate drug crimes throughout the Commonwealth. View "Commonwealth v. Johnson" on Justia Law

In 2005, Appellant entered an Alford plea to eleven counts of first-degree robbery and was sentenced to twenty-one years imprisonment. In 2008, Appellant filed a pro se motion to vacate his sentence pursuant to Ky. R. Crim. P. 11.42, alleging that his counsel had provided ineffective assistance by misinforming him that he would be eligible for parole when he had served twenty percent of his sentence. The trial court denied the motion without conducting an evidentiary hearing. Appellant appealed, arguing that the trial court erred in failing to grant an evidentiary hearing on the specific allegation of ineffective assistance of trial counsel pertaining to his parole eligibility. The court of appeals concluded that Appellant failed to preserve his right to appeal the summary denial of his Rule 11.42 motion because he did not request additional findings pursuant to Rule 11.42(6). The Supreme Court reversed, holding that Appellant did not waive his right to appeal the trial court’s failure to hold an evidentiary hearing on his Rule 11.42 motion. View "Cawl v. Commonwealth" on Justia Law